tax Advice Archive
TweetShareSharePin0 Shares Over the last two years I cannot count the number of times I’ve had to give extraordinarily unsatisfying advice to my clients. That advice being, “please wait.” Wait for the IRS to process your return. Wait for the refund to be issued. Wait for your Collection Due Process hearing. Of course, waiting can
TweetShareSharePin0 Shares While the individual income tax filing season ended Monday, Treasury and the IRS will continue gathering feedback as part of efforts over the past year and looking ahead to make the tax system more equitable and fair, according to Treasury’s Equity Action Plan: One Year Progress Report released last week. The report documents
TweetShareSharePin0 Shares In In re Big Apple Energy, LLC, No. 8-18-75807 (Bankr. EDNY 2022), the owner of a business that failed to pay the taxes withheld from employees over to the IRS sought an order that the bankruptcy trustee was personally liable for the interest and penalties arising from the failure. In rejecting this claim,
TweetShareSharePin0 Shares The IRS provided temporary relief from a penalty for failure to deposit Superfund excise taxes and affirmed the availability of a safe harbor for deposits. The relief in Notice 2022-15 released Friday applies to semimonthly deposits due in the third and fourth calendar quarters of 2022 and the first quarter of 2023. In
TweetShareSharePin0 Shares The U.S. Supreme Court declined Monday to review an appellate case that upheld the $10,000 limit on the amount of state and local taxes (SALT) that can be claimed as a deduction on individual federal income tax returns. The Court’s order list included a denial of certiorari for New York v. Yellen, No.
TweetShareSharePin0 Shares We have not covered IRC 66(c) relief from community property taxation in detail on PT before. Keith wrote about the 2018 case of U.S. v. Kraus, where the grant of personal relief under IRC 66 failed to lift the federal tax lien or prevent foreclosure of the lien. (Similar hurdles exist with IRC
TweetShareSharePin0 Shares We welcome back guest blogger Barbara Heggie. Barb is the supervising attorney for the Low-Income Taxpayer Project of 603 Legal Aid in Concord, New Hampshire. Her clinic serves taxpayers through the Granite State and is the only LITC in the state. Today, she describes a recent experience in trying to assist a client.
TweetShareSharePin0 Shares The question of when a supervisor must give approval for imposition of a penalty has created much litigation in the Tax Court as taxpayers try to remove a penalty proposal by using the failure of the IRS to comply with the IRC 6751(b) approval process. In Laidlaw’s Harley Davidson Sales v. Commissioner, No.
TweetShareSharePin0 Shares When Congress passed the Foreign Account Tax Compliance Act (FATCA) (as part of the Hiring Incentives to Restore Employment Act, P.L. 111-147) in 2010, the Joint Committee on Taxation estimated it would bring in $8.7 billion in revenues in the next 10 years. To that end, the IRS drafted an ambitious, agencywide FATCA
TweetShareSharePin0 Shares News PARTNERS & PARTNERSHIPS By Paul Bonner The IRS has added eight new questions and answers to its website’s frequently asked questions (FAQs) on Schedules K-2 and K-3, clarifying that affected partnerships and S corporations need complete only the forms’ relevant portions and addressing an array of special circumstances. The new material